Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Recordkeeping and Disclosure Requirements-Consumer Financial Protection Bureau Regulations B, E, M, Z, and DD and Board of Governors of the Federal Reserve System Regulation CC
Agencies
ELI5 AI
The government wants to hear what people think about some rules that help keep money stuff fair, and they want ideas on how to make it easier and less time-consuming for people to share their thoughts.
Summary AI
The Office of the Comptroller of the Currency (OCC) is seeking comments from the public and other federal agencies on renewing an information collection. This collection is required under the Paperwork Reduction Act and includes various Consumer Financial Protection Bureau regulations and the Federal Reserve System's Regulation CC. The OCC wants feedback on the necessity and utility of collecting this information, ways to improve its quality and clarity, and how to reduce the burden on respondents. Comments are due by February 10, 2021, and can be submitted via email, mail, or fax.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to comment on the renewal of an information collection, as required by the Paperwork Reduction Act of 1995. An agency may not conduct or sponsor, and a respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning the renewal of an information collection titled, "Record and Disclosure Requirements--Consumer Financial Protection Bureau Regulations B, E, M, Z, and DD and Board of Governors of the Federal Reserve System Regulation CC." The OCC also is giving notice that it has sent the collection to OMB for review.
Keywords AI
Sources
AnalysisAI
The document in question is a notice from the Office of the Comptroller of the Currency (OCC), which is under the Treasury Department. It calls for comments on the renewal of an information collection related to various consumer financial regulations overseen by the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve. The notice is part of the Paperwork Reduction Act's requirements to minimize paperwork and respondent burden associated with information collection.
General Summary
The purpose of the document is to inform the public and seek their feedback on renewing an information collection initiative that includes regulations intended to protect consumers. It references several specific regulations (B, E, M, Z, DD, and CC) that pertain to various financial transactions and consumer protections. These include issues like preventing discrimination in credit, protecting digital fund transfers, ensuring clarity in leasing and lending, and governing the availability of funds.
Significant Issues
One notable issue with the document is its complexity. The language is technical and may include terms that are unfamiliar to a general audience, potentially limiting participation from the public who may not fully grasp the document's implications. Furthermore, the process for submitting comments—though outlined—is filled with procedural details that may discourage engagement due to its perceived intricacy.
Another concern is the estimated annual burden of nearly 3 million hours. This figure might be viewed as excessive or bureaucratic if the value of the collected information is not well articulated. Furthermore, the document does not provide alternative approaches to collecting this information, which could help reduce the burden on businesses and other entities required to comply.
Public Impact
For the broader public, this document represents an opportunity to engage with and provide input on federal regulations that impact consumer financial rights and protections. While the notice aims to gather feedback to improve regulatory practices, its technical nature might limit broader public participation unless simplified or better explained.
Impact on Specific Stakeholders
Businesses and financial institutions are the most directly impacted stakeholders, as they are the entities required to comply with these regulations. For these groups, the renewal of the information collection may result in continued administrative burdens. However, it also provides a platform to suggest improvements and voice concerns about current practices, which could potentially lead to more streamlined processes in the future.
In contrast, consumers might indirectly benefit from more robust regulatory practices that ensure their financial activities are protected and their rights are respected. However, for this to be effective, regulators must consider public feedback and strive to make these processes more transparent and less burdensome.
Overall, while the document's goal is to solicit meaningful input to enhance regulatory efficacy, more effort may be needed to ensure that feedback is accessible and clearly understood by all parties involved.
Issues
• The document's language is technical and may be difficult for a general audience to understand, particularly the references to various regulations and legal requirements (Regulations B, E, M, Z, DD, and CC).
• The document provides a significant amount of detailed bureaucracy around the process of submitting comments, which could potentially deter participation from interested parties who find the process cumbersome.
• The estimated annual burden of 2,937,280 hours is considerable and could be perceived as wasteful or excessive if not adequately justified by the utility of the information collected.
• The document lacks detail on what the expected benefits or outcomes of the information collection are, leaving the practical utility of this effort somewhat unclear.
• There is no mention of any alternatives to the current methodology for information collection, which might minimize the burden on respondents.